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Kent Greenfield

Kent Greenfield

Posted: January 22, 2010 12:43 PM

A Way Out of the Citizens United Mess?

What's Your Reaction:

Thursday's Supreme Court decision in Citizen's United v. FEC is perhaps the most activist decision of the Supreme Court since Bush v Gore, and might be just as harmful to the nation.

There is a way out of this mess, but it will take quick action.

The Court struck down limits on corporate expenditures in elections, insuring that -- in the name of free speech -- the speech of those of us who are real, breathing humans will be drowned out by the blather of Walmart, Goldman Sachs, ExxonMobil, and other for-profit corporations. In the Court's view, there is no difference between the speech rights of humans and the speech rights of artificial entities created to make money.

The Court struck down its own precedent, ruled a portion of the McCain-Feingold election law unconstitutional, and overturned limits on corporate electioneering that have been a part of federal law for more than a century. The Court did so in a case in which neither party had asked for such rulings. Rather, the Court itself asked the parties -- after they had already been to the Court once -- to re-argue the case for the express purpose of giving the Court the opportunity to overturn settled law.

Anytime the Court strikes down a law on constitutional grounds, it is difficult to un-do. For this reason, the Court has long claimed the importance of restraint. The Court has said it will defer to the political branches if the constitutional question is a close one, and the Court has also said that it will not go out of its way to decide constitutional questions it can avoid.

The Court offended all of these notions in its opinion. It reached out to decide constitutional issues it did not have to decide, overturning careful election regulations decided by bipartisan coalitions in Congress.

There are not many options for redressing the mistakes of today's opinion. (Rick Hasen lists six, none of which he thinks will work.)

But there is one possibility.

Corporations are created ("chartered") by states, and such chartering gives them special abilities to make money. Limited liability and unlimited life are two of the most powerful benefits so bestowed.

In my view, the benefit of incorporation itself can be conditioned on the waiver of the "right" of corporations to participate in political campaigns. The Court has often upheld the ability of government to condition benefits on the waiver of rights. Admittedly, this gets complicated fast, but the basic rule is that if the government gives you something, it can limit the uses you make of it.

So if the limits on campaign expenditures of corporations were not a part of election law but a part of corporate law - then the limits would be much more easily defended.

The change would be straightforward. Now, most states charter corporations "for any and all lawful purposes." The only change required would be for the statute to add "except that any entity created by this charter shall not have the power to expend money to influence the outcome of any local, state, or federal election."

But these changes would have to come fast. Starting today, corporations can spend as much money as they want to skew elections at every level of government. Efforts to amend corporate statutes to make it clear that corporations should stay out of politics will not be greeted warmly by the corporate elite. If these amendments are delayed until most elected officials owe their jobs to corporate benefactors, then we can kiss these changes -- and perhaps genuine democracy -- goodbye.

 
 
 
Thursday's Supreme Court decision in Citizen's United v. FEC is perhaps the most activist decision of the Supreme Court since Bush v Gore, and might be just as harmful to the nation. There is a wa...
Thursday's Supreme Court decision in Citizen's United v. FEC is perhaps the most activist decision of the Supreme Court since Bush v Gore, and might be just as harmful to the nation. There is a wa...
 
 
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HUFFPOST COMMUNITY MODERATOR
rusane
My micro-bio is empty, cold and jaded.
09:03 PM on 01/23/2010
Just quoted this article in a letter to my State Governor and Legislature. Please do the same.

Please also press for a clear and lasting separation of corporation an State to be added to the US Constitution, we need 2/3 of the state legislatures to call for a convention.

In the mean time, petition capitol hill,

movetoamend.org dontgetrolled.org freespeechforpeople.org
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HUFFPOST BLOGGER
Kent Greenfield
Law Professor, Author
08:41 AM on 01/23/2010
I have added to this proposal in an op-ed in today's Boston Globe. See: http://www.boston.com/bostonglobe/editorial_opinion/oped/articles/2010/01/23/a_campaign_funding_mess/
08:16 PM on 01/23/2010
Nice work Kent.

I'm spreading this far and wide to all my reps.

Thanks
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DavidBlackburn
Recovering Republican since 1995.
05:14 AM on 01/23/2010
What about eliminating tax deductions for any expenditure associated with influence upon any law, including advertising, information published about candidates or office holders or money paid to lobbiests?
11:22 PM on 01/22/2010
The Boston Tea Party was an act of defiance by our Founding Fathers against unchecked corporate power.

In Humboldt County we also know what it's like to be pushed around by large corporations. In 1999 Wal-Mart spent $250,000 in an attempt to change Eureka's zoning laws. In 2004 Maxxam spent $300,000 trying to recall our District Attorney after only three months in office. The price to fight these giants and defend our democracy came at a tremendous cost.

Unelected judges and corporate lawyers claim that corporations are legal "persons" with the same rights as human beings. "Corporate personhood" weakens people's rights to free speech and equal protection. Our Founding Fathers never intended corporations to have this kind of power.

Any corporation rich enough to sue can claim that laws protecting workers, the environment, communities, or small businesses violate their "rights."

Large corporations have used their "personhood" status to gain access to the ballot box and spend obscene amounts of money on push polling, paid petitioners and high-priced consultants.

It's time for a "T" Party of our own...
It's time for Measure T!
Measure T will protect local control by ensuring that only individuals, local organizations and local businesses can make financial contributions in Humboldt County elections.

http://www.votelocalcontrol.org/
10:12 PM on 01/22/2010
KENT: I HOPE YOU HAVE STARTED SOMETHING. THE NEXT STEP IS HOW TO CREATE AN ORGANIZATION TO PURSUE ALL OPTIONS, AND THERE ARE MANY GOOD ONES, INCLUDING YOURS. ART B
06:57 PM on 01/22/2010
If these amendments are delayed until most elected officials owe their jobs to corporate benefactors.

I think it is already to late. Most if not all elected officials owe their jobs to corporate lobbyist and the like.
They should be like Nascar and where the logo of their sponsors on their Jackets.
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Miles Mogulescu
06:29 PM on 01/22/2010
The potential problem with this idea, other than whether this Supreme Court would reject it, is that large corporations shop for the state with the most favorable laws for them to incorporate in. Most cases large corporations incorporate in Delaware because of their favorable laws. This first place the change in corporate law would need to be made is Delaware. But that would mean that corporations would just reincorporate in other states that don't a restriction on corporate contributions. And Delaware is unlikely to make the change, because it would lose business if corporations relocated. In any case, there would always be at least one state which would pass corporate friendly laws to attract the business of large corporations incorporating there.
Any further thoughts on this?
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Kent Greenfield
Law Professor, Author
07:29 PM on 01/22/2010
Miles -- you're certainly correct about the power of Delaware. I have two possible work-arounds to propose. First, other states can simply begin to assert the power to regulate corporations with significant connections within their state. The requirement that corporations not engage in political activity could come as a condition not of incorporation but of registration in the state to do business. My friend Dan Greenwood proposed something similar on the ACS blog yesterday. (See http://www.acslaw.org/node/15154). The better idea is to have Congress enact a federal incorporation statute. As a condition of being registered on a national securities exchange, corporations would have to be chartered at the federal level. And as a condition of receiving such a charter, the corporations would have to agree not to attempt to influence electoral politics.
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Miles Mogulescu
01:51 AM on 01/23/2010
Might be worth exploring. I don't know enough about the interplay between state corporate law and federal securities law.
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03:02 AM on 01/23/2010
Glad qstn was asked/answered. I also immediately thought of the so-called "right-to-work" anti-union (and even anti-minimum wage) states. I think the federal incorporation statute idea is best. I've also been wondering: Can we make it illegal for them to influence electoral politics if even one shareholder or even one employee is not a U.S. citizen? Isn't citizenship required in existing federal political donation laws already?
05:44 PM on 01/22/2010
I would support an effort such as Professor Greenfield proposes, if only to buy time for a more permanent solution. I would warn that a court majority activist enough and radical enough to give the Citizens United decision, is probably capable of declaring any new limits on corporations unconstitutional as obvious attempts to limit corporations' First and Fourteenth Amendment rights. The logic of Harper v Virginia Board of Elections could easily be adapted for this purpose. There may also be a Contract Clause (Article I, Section10) problem.

I would argue that, since a constitutional amendment is impractical (certainly in the time available), the only long-term solution is to have the Court reverse itself. How, since conservative majority are not likely to change their minds and all appear to be in reasonable health?

Increase the size of the Court from nine to eleven, thus giving Obama the opportunity to appoint two new justices who, with the original minority of four, would now represent a new majority of six. This would be perfectly legal since Article III gives Congress the power to set the size of the Court.

As for the inevitable filibuster, threaten to use (or actually use if necessary) the :nuclear option" outlined by the Republicans in 2005.

This solution could be implemented very quickly and only requires simple majorities.

Under normal circumstances, I would argue against packing the Court and the nuclear option, but these are not usual times and the alternative of doing nothing is unacceptable.
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03:07 AM on 01/23/2010
Oh, how I wish such a logical step could be taken! But we all know the Senate, especially, is packed with members in both parties irredeemably indebted to the corporations in their respective states. Why else did they sit with their fingers in their noses, while they knew full well this decision was coming? Far as I know, only Alan Grayson, Dem representative of FL, and independently wealthy btw, bothered to get ahead of the ruling [barely] to propose multiple bills to undo the damage of the ruling.
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DantesE
04:14 PM on 01/22/2010
Look it is not all doom and gloom. The court removed limits on advertising but keep the disclosure requirements. So how do I as an individual use this? First I pay close attention to who is paying for the ad. Then I pay attention to who benefits from the ad. The court said that X amount of dollars spent for candidate Y does not mean there is a quid pro qua for the corporation that spent X dollars. You know and I know this is a lie. As individuals we can start by associating massive advertising to corruption. So who ever the ads are for vote against them. We can nullify this affront to Democracy by actively practicing Democracy. We can become informed. We can vote against the commercials. I personally never vote for the candidate who has the most adds. That candidate has to pay that money back one way or another. Same with the commercials. Any corporate sponsored ad is against me and for the corporation. I vote no. We the People can and should make these changes to how we think.
04:57 PM on 01/22/2010
My thoughts exactly Dante, we the, informed, people will be the real combat against this.
I kinda like the idea of officials wearing logo attire for the biggest companies funding them, I'm tired of the suit and tie look anyway.
Fanned
07:39 PM on 01/22/2010
So you think the Americal people - those who believed Louise and her husband - would do the work and take the time to check out these commercials. Boy you have more faith than I do.
10:08 PM on 01/22/2010
I LIKE YOUR ATTITUDE. BUT I AM AFRAID YOU OVERESTIMATE THE ATTENTION SPAN OF THE GENERAL PUBLIC. A BETTER WRINKLE IS TO CREATE AN ORGANIZATION DEVOTED TO EXPOSING THE SOURCES MORE PUBLICLY AND THEN SHOWING HOW THE ADVERTISEMENT ASSIST THE CORPORATE ADVERTISER.
02:54 PM on 01/22/2010
Does this mean a state-by-state attempt to dissolve this monster? If so, this breath of hope sounds like an expiring gasp.
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HUFFPOST SUPER USER
plaidsportcoat
02:49 PM on 01/22/2010
Thank you for doing this close reading! I hope to hear more of these kinds of suggestions - THIS WEEK!!